Blue Goat CyberBlue Goat Cyber(844) 939-4628Call
    FDA Premarket Cybersecurity

    FDA Premarket Cybersecurity, Reviewer-Ready

    FDA premarket cybersecurity submission services aligned to the FDA February 2026 final guidance and Section 524B.

    The cybersecurity section is the #1 cause of acceptance-checklist holds on premarket submissions. We return a fixed-fee quote within 24 hours of the discovery call so you know exactly what's missing before you submit.

    Every artifact the FDA expects in a premarket cybersecurity submission - SPDF, SBOM with VEX, threat model, penetration test report, and Section 524B attestation - delivered eSTAR-ready by a senior US-based team. Aligned to the FDA February 2026 final premarket cybersecurity guidance. 250+ FDA submissions supported, zero cybersecurity rejections.

    • eSTAR-ready premarket cybersecurity sections
    • Section 524B(b)(1)-(3) documentation
    • SBOM (SPDX or CycloneDX) with VEX statements
    • STRIDE threat model + security risk assessment
    • Penetration test report (device, cloud, wireless, mobile)
    • Cybersecurity labeling + customer security guide

    Free 30-min call · Senior US expert · Mutual NDA before the call

    FDA submissions supported
    250+
    Cybersecurity rejections
    0
    Quote turnaround
    24 hrs

    Last updated

    Blue Goat Cyber takes the burden off our engineers and makes FDA cybersecurity requirements easy to understand. Their expertise and smooth process mean we can focus on our pro…

    Amy Lynn, Chief Compliance Officer, Medivis

    • Intuitive
    • Natera
    • bioMérieux
    • Inogen
    • VitalConnect

    Trusted by medical device teams worldwide

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    Lifecycle scope

    What's in your premarket cybersecurity package

    Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.

    01

    FDA 2026 final guidance aligned

    Built to the February 2026 final premarket cybersecurity guidance. Every artifact maps to the section the FDA reviewer is looking for.

    02

    eSTAR-ready attachments

    Drops directly into eSTAR for 510(k), De Novo, and PMA submissions - no reformatting, no missing attachments, no acceptance-checklist surprises.

    03

    Secure Product Development Framework

    SPDF integrated into your QMSR (21 CFR 820) and ISO 13485 processes with full traceability from requirement to verification evidence.

    04

    SBOM + VEX

    Machine-readable SPDX or CycloneDX SBOM with NTIA minimum elements (now stewarded by CISA), support-end dates, and a VEX statement for every CVE in your shipping configuration.

    05

    Threat model + risk assessment

    End-to-end STRIDE threat model with multi-patient harm, updateability, and use-environment views. Aligned to AAMI TIR57 and ANSI/AAMI SW96.

    06

    Unlimited revisions included

    Fixed fee. Retests and revisions are included until the cybersecurity portion of your submission is closed. No per-cycle invoices.

    Common FDA findings

    The premarket cybersecurity gaps reviewers cite most

    These are the issues showing up in real FDA acceptance-checklist holds and cybersecurity deficiency letters under the February 2026 final guidance.

    Missing Section 524B(b)(1) postmarket plan

    Premarket package lacks a vulnerability monitoring + coordinated vulnerability disclosure plan. Required for every cyber device.

    SBOM without VEX statements

    Bare SBOM ships with unresolved CVEs and no exploitability analysis. Reviewer requires VEX for every applicable vulnerability.

    Threat model without traceability

    STRIDE entries exist but no mapping to mitigations, test evidence, or residual risk. Reviewer requests full SW96 / TIR57 traceability matrix.

    Pen test missed the full attack surface

    Device firmware tested but cloud backend, mobile companion, and wireless interfaces skipped. Reviewer requires every interface in scope.

    SPDF written as standalone doc

    Secure Product Development Framework not integrated into existing QMSR / ISO 13485 design controls. Reviewer flags missing traceability.

    No reasonable-assurance narrative

    Artifacts ship without a narrative tying threat model, controls, and test evidence into a defensible reasonable-assurance conclusion.

    Blue Goat Cyber vs. the alternatives

    What you actually get versus a generic 510(k) consultant or building the cybersecurity package in-house.

    Capability Blue Goat Cyber Generic 510(k) consultant In-house
    Mapped to FDA February 2026 final guidance + 524B Section-by-section, reviewer-format Legacy template, often out of date Built from scratch each submission
    SPDF + threat model + SBOM + VEX All deliverables, one team Outsourced piecemeal across vendors Multiple internal owners, gaps emerge
    FDA submission track record 250+ submissions, zero cyber rejections Limited cyber-specific experience First-submission risk
    Pricing model Fixed fee, unlimited revisions until accepted Hourly + change orders Hidden internal cost
    Mutual NDA before first call Standard, signed day 0 Usually after SOW n/a
    FDA Feb 2026 Guidance · §524B · eSTAR v7.0

    Every premarket cybersecurity deliverable. Mapped to the eSTAR slot it lives in

    What happens after you book the call

    1. 1Day 0

      Mutual NDA + 30-min premarket scoping

      We sign a mutual NDA, then walk your device, submission type, and the cybersecurity evidence the FDA reviewer will expect.

    2. 2Day 1

      Point-by-point gap list + fixed-fee quote

      Point-by-point gap list against Section 524B and the FDA February 2026 final guidance, each gap mapped to the artifact that closes it, with a fixed-fee quote covering every deliverable.

    3. 3Weeks 2-8

      eSTAR-ready premarket cyber package

      SPDF, SBOM with VEX, threat model, pen test report, and cybersecurity labeling - delivered in eSTAR-attachable format, reviewer-ready.

    "Blue Goat Cyber takes the burden off our engineers and makes FDA cybersecurity requirements easy to understand. Their expertise and smooth process mean we can focus on our product, not the paperwork. The organized documentation, perfectly formatted for eSTAR, saves us countless hours."
    - Amy Lynn, Chief Compliance Officer, Medivis

    Cybersecurity deficiency remediation included

    If the FDA raises a cybersecurity deficiency, we fix it at no additional cost. 250+ FDA submissions, zero cybersecurity rejections to date.

    Mutual NDA before the call

    We sign a mutual NDA before the initial call so you can share device details, architecture, and FDA correspondence freely.

    Fixed-fee quote within 24 hours of the call

    No sales pressure. After the call, you get a concrete written strategy mapped to Section 524B and the FDA February 2026 final guidance.

    Senior US engineers, fixed fee

    Senior-led delivery on every FDA-facing artifact. No offshoring, no hourly billing. Unlimited revisions. Every artifact is eSTAR-ready.

    Common questions

    Christian Espinosa, Founder & CEO of Blue Goat Cyber

    Who you're talking to

    Christian Espinosa, Founder & CEO

    MBA, CISSP · U.S. Air Force Academy graduate · 30+ years in cybersecurity

    Christian leads the senior medical device cybersecurity team behind 250+ FDA submissions, zero cybersecurity rejections. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.

    Ready to talk to a senior expert?

    30 minutes with a senior medical device cybersecurity engineer. Mutual NDA signed before the call. No pitch - we'll tell you straight if you don't need us.

    Replies in 1 business dayMutual NDA firstUS-based senior engineerNo sales pitch